- 4 - The RTVUE showed that petitioner reported negative adjusted gross income in the amount of $2,235,940 and a total tax liability in the amount of $13,733. The parties do not dispute that the amounts listed on the RTVUE correctly reflect the amounts reported on petitioner’s 1994 return. Petitioner did not report any dividend income for the 1994 tax year. On October 7, 1997, respondent sent petitioner a Form 4549- CG, Income Tax Examination Changes, together with a Form 4564, Information Document Request, requesting copies of petitioner's 1993 and 1994 tax returns. At that time, respondent also requested that petitioner verify the net Schedule E losses in the amount of $973,006 and net operating losses in the amount of $1,795,146. Even though the examining agent contacted both petitioner and petitioner's counsel several times, neither provided copies of petitioner’s 1993 and 1994 tax returns nor verified the losses as requested. Respondent mailed a notice of proposed income tax changes (30-day letter) to petitioner on November 6, 1997. Respondent concluded that petitioner had received $356,124.92 from Levitz and that only $47,579.12 of this amount was a nontaxable return of capital. Respondent also concluded that petitioner had overstated his net Schedule E losses in the amount of $973,006 and net operating loss deductions in the amount of $1,795,146. Respondent calculated that petitioner had a corrected taxablePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011